Compliance Q&A: OFAC, FCRA, and the SAFE Act

When must mortgage loan originators be fingerprinted?

Q Does a credit union need to file the Office of Foreign Assets Control’s (OFAC) Annual Report of Blocked Property if it has had no “hits” on the Specially Designated Nationals (SDN) and Blocked Persons List in the past year?

Credit unions must report all blockings to OFAC within 10 business days of occurrence, and file a comprehensive annual report (Form TDF 90-22.50) by Sept. 30 each year of all blocked property held as of June 30.

There’s no need to file the annual report if the credit union has had no “hits” on the SDN List and holds no blocked property.

What's Trending

FinCEN's new customer due diligence requirements for business accounts are effective May 18, 2018, and CUNA’s compliance staff has received a number of questions. A recent CompBlog post examines CDD procedures and requirements.